G.R. No. 141599 - People vs. Gonzales

The case is Criminal Case No. 98-371, decided on December 27, 1999, by the Regional Trial Court, Branch 259 in ParaAaque City.
The appellant, Christian Gonzales y Cayubit, was convicted for rape—a crime defined under Article 335 of the Revised Penal Code as amended by RA 7659—and sentenced to the death penalty by lethal injection.
The trial court also imposed a monetary award, initially set at P50,000.00 for civil indemnity and P50,000.00 as exemplary damages against the appellant.

The Information charged that in August 1997, in the Municipality of ParaAaque, the appellant, by means of force and intimidation, committed rape against his 15-year-old daughter, Mary Grace Gonzales, thereby violating her will and consent.
Details of the sexual abuse indicate a pattern of violence:

In 1992, when Mary Grace was nine years old and a Grade III pupil, the appellant abused her when she sought his help with school assignments during a prayer session at home. He forced her to remove her clothes and touched her private parts.
In 1994, while Mary Grace was in Grade V, the appellant again assaulted her in their family room. He entered abruptly, locked the door, showed her a fan knife to ensure compliance, ordered her to undress, and then forcibly inserted his penis into her vagina.
The abuse recurred on several occasions, culminating in the last incident in August 1997 when Mary Grace, then a high school sophomore, was again sexually assaulted in her room as she was doing her homework.

The victim’s detailed testimony described the methodical manner in which the abuse was committed, including:

Forcing her to remove her short and underwear and subjecting her to unwanted physical contact.
Employing physical force, intimidation, and the display of a weapon (balisong) to prevent resistance.

On March 24, 1998, Mary Grace confided in her best friend, Bryan Esteban, about the abuse, which led to a police report and subsequent complaint for rape.
A medico-legal examination by Dr. Valentin Bernales produced findings that supported the occurrence of sexual abuse, notably an old-healed complete laceration on the hymen consistent with forced sexual intercourse.
Documentary evidence included a Certificate of Live Birth confirming Mary Grace’s age and a Marriage Certificate substantiating the familial relationship between the appellant and Mary Grace.

Appellant and Lydia Gonzales were married on June 21, 1981, and have four children, including Mary Grace who was born on January 26, 1983.
The family resided in a two-storey house in ParaAaque City, a location where the abuse purportedly occurred.

At arraignment, the appellant pleaded not guilty and offered an alibi predicated on his work at the MMDA in Pasig City, alleging that his presence there on weekdays made it impossible for him to be at home during the alleged times of the offenses.
He attempted to shift the explanation to issues of discipline regarding Mary Grace’s tardiness and association with suitors.

The trial court, after extensive pre-trial and trial proceedings, found the appellant guilty beyond reasonable doubt of qualified rape.
In imposing the penalty, the trial court considered the qualifying circumstance of the father-daughter relationship and the victim’s age.
While the appellate decision affirmed the death penalty, it modified the awards to P75,000.00 as civil indemnity, P75,000.00 as moral damages, and P25,000.00 as exemplary damages.

Whether the conviction for rape was supported by sufficient evidence despite the appellant’s contention that the victim’s testimony was uncorroborated.
Whether the trial court erred in dismissing the defense’s alibi and other testimonial evidence that sought to prove the appellant’s non-presence at the scene during the alleged events.
Whether the spontaneous and credible testimony of a rape victim, even if not corroborated by additional evidence, is enough to convict the accused beyond reasonable doubt.
Whether the imposition of the death penalty, under the qualifying circumstances of minority and familial relationship, was proper and legally sustainable.